If you've taken the time to read and understand the Consolidated Appropriations Act of 2021, you will have learned three things:

1. It's time you knew exactly how much and how your employee benefits broker is paid.

2. If you haven't yet, setting up a health plan fiduciary committee should be a top priority, whether yours is a fully or self-funded health plan.
3. Employers that fail to comply with the legislation may escape regulatory scrutiny for a while, but will want to brace for the onslaught of lawsuits filed by plaintiffs' lawyers eager for any excuse to drag them into court.

Anyone in the C-suite who hasn't had a chance to dig into the nitty-gritty of the CAA is to be forgiven. It is, after all, a 5,600-page law that has gotten little media attention aside from provisions related to ending what's known as "surprise billing."

That's an important, new consumer protection. But the legislation does considerably more by adding a level of transparency to health care that, well, we've never seen before.

For plan sponsors – a.k.a., any company offering health insurance to its employees – the CAA is a new compliance obligation but also an altogether new transparency tool to ensure their broker payouts aren't being padded by hidden commissions.